DOCKET SECTtON
BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, D.C. 20268-0001
POSTAL RATE AND FEE CHANGES, 1997
Docket No. R97-1
j
RESPONSE OF UNITED STATES POSTAL SERVICE
VVITNESS MODEN TO INTERROGATORIES
OF
THE DIRECT MARKETING ASSOCIATION, INC.
(DMAIUSP%T4-55,
56, 60-62)
The United States Postal Service hereby provides responses of witness Moden
to the following interrogatories
T4--55,
of the Direct Marketing Association,
56, 60-62, filed on September
DMAIUSPS-T4-57
USPS-T4-58
Inc.:
DMA/USPS-
15, 1997. An objection to interrogatories
and 59 was filed on September
25, 1997.
lnt.errogatory
DMAf
was redirected to the Postal Service
Each interrogatory
is stated verbatim and is followed by the response.
Respectfully
submitted,
UNITED STATES POST,AL SERVICE
By its attorneys:
Daniel J. Foucheaux,
Scott L. Reiter
475 L’Enfant Plaza West, S.W.
Washington, D.C. 20260-l 137
(202) 268-2999; Fax -5402
September 29, 1997
Jr.
RESPONSE OF UNITED STATES POSTAL SERVICE WITNESS MODEN
TO THE INTERROGATORIES
OF THE DM.4
DMANSPS-T4-55.
Has the Postal Service ever performed studies to determine the
regional, seasonal, or temporal variations in MODS conversion factors? If so, please
provide the results of these studies, indicate when they were performed, and produce
them as library references.
Response:
I am not aware of any such studies
.--
RESPONSE
DMNUSPS-T4-56.
OF UNITED STATES POSTAL SERVICE WITNESS
TO THE INTERROGATORIES
OF THE DMA
MODEN
(a) When was MODS implemented?
(b) Was its predecessor system the Workload Recording
(“WLRS”)?
Response:
a. I am told it was 1973.
b. Yes
System
RESPONSE
DMANSPS-T4-60.
OF UNITED STATES POSTAL SERVICE WITNESS MODEN
TO THE INTERROGATORIES
OF THE DMA
(a) What organization
maintaining MODS?
within the Postal Service is responsible
(b) When did the organization identified in subpart (;a) become
responsible for maintaining MODS?
for
’
(c) Which organization within the Postal Service was responsible for
maintaining MODS before the organization ident:ified in subpart
(a)?
Response:
a. Operations
Support
b. It has always been Operations
Operations
c. n/a
Support
Support, although the responsible
has changed with successive reorganizatiors
subgroup within
RESPONSE
OF UNITED STATES POSTAL SERVICE WITNESS
TO THE INTERROGATORIES
OF THE DMA
MODEN
DMANSPS-T4-61.
Please describe and provide copies of all national reports
produced by MODS. Please also descrrbe the purpose of each report, its distributron,
the frequency of production, and the date of inception of the report.
Response:
The MODS system itself does not produce any national reports.
reporting of MODS data is accomplished
Corporate
subsystems
Inskad,
national
through MODS subsystems ,within the
Information System (CIS) and Executive Information Systern (EIS). These
provide an elaborate set of options to select the desired data elements,
time periods, operations,
geographic areas, type of report, etc. The requested report is
generated on demand based on the selected options.
RESPONSE
OF UNITED STATES POSTAL SERVICE WITNESS MODEN
TO THE INTERROGATORIES
OF THE DMA
DMNUSPS-T4-52.
(a) In MODS offices, does an individual’s clocked MODS hours
provide the basis for paying that individual?
(b) If the response to subpart (a) is “no,” what data system is used for
determining the hours worked by an employee?
(c) If an employee’s hours are revised from what is clocked into
MODS during the course of a pay period or after a pay period, are
the hours by operation also changed in the MODS data?
(d) If your response to subpart (c) is “yes,” please explain whether
changes in hours of operation have always occurred when an
employee’s hours were changed.
(e:) If your response to subpart (d) is “no,” when was the change in
operation hours made?
Response:
a. Yes.
b. n/a
c. Yes.
d. It is my understanding
the responsible
e. n/a.
that this has always been the policy. Of course, on occasion
personnel may forget to make the change.
DECLARATION
I, Ralph J. Moden, declare under penalty of perjury that the foregoing
answers are true and correct, to the best of my knowledge,
information
and
belief.
Dated:
/
/
-
__-
CERTIFICATE
OF SERVICE
I hereby certify that I have this day served the foregoing document
participants
of record in this proceeding
in accordance
with section 12 of the Rules of
Practice.
Scott L. Reiter
475 L’Enfant Plaza West, S.W.
Washington, D.C. 20260-I 137
September 29, 1997
-.
upon all